The Italian Supreme Court has delivered a judgment stating that a fair market value price analysis must be applied to domestic intra-group transactions, despite section 111 of the Italian Tax Code providing that the country’s transfer pricing rules only apply to transactions between Italian and foreign related entities.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
Pillar two compliance is creating unprecedented data demands for multinational tax departments, making closer collaboration with FP&A teams essential for accurate reporting and audit readiness
ITR's podcast examines whether the big four have overarching cultural issues and assesses the competitive threat of technology-backed transfer pricing firms
From Mauritius substance rules to Kenyan SEP tax and South African anti-avoidance measures, businesses must navigate growing scrutiny of cross-border IP structures in Africa
ITR spoke to multinationals, advisers and software providers about a June 30 deadline defined by faulty portals, high compliance costs and hard lessons
Tax advisers should revisit India secondment arrangements after the EY US ruling strengthened the Centrica precedent and raised fresh withholding concerns